QA2022-32 - SRBDQ 0272, 0289, 0306 & 0307
Atribute | Detail |
---|---|
Resolution Reporting Subject Matter | Taxonomy |
Guidance Documents | - |
Taxonomy | SRB-extension |
Unique Identifier |
QA2022-32 |
Question
These checks (SRBDQ 0272, 0289, 0306 & 0307) verify if a security is "secured" then the column "amount of pledge, lien or collateral" is different from "0".
We believe these controls are incorrect because, in our opinion, some liabilities can be secured even though the collateral posted equals 0. In fact, in the answer to the Q&A SRB 2018-24 and 2019-89, such liabilities are mentioned: 'such a liability shoud be reported under 'uncollateralized secured liabilities', even in case the amount of collateral posted is zero'.
Do you confirm that we can send our LDT statement without taking into account these controls? Will you remove these controls for the next closing?
Response
The severity of the controls is set to "warning" as the possibility exists that in some cases the rule may not apply to a given reporting entity. Given this flexibility (the file will not be automatically rejected by the SRB), we will maintain the rule as is.
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